ALICE Privacy Policy

This Privacy and Cookie Policy (the "Policy") becomes effective on July 31, 2018 for all users. Prior to July 31, 2018, the version of the Privacy Policy found here remains effective.

INTRODUCTIONCOLLECTION OF INFORMATIONUSE OF INFORMATIONDISCLOSURE OF INFORMATIONRETENTION OF INFORMATIONYOUR CHOICES AND RIGHTSCHILDREN’S PRIVACYTHIRD-PARTY LINKS AND CONTENTDO-NOT-TRACK SIGNALS AND SIMILAR MECHANISMSPCI RESPONSIBILITYINTERNATIONAL USERSSECURITYCHANGES TO THIS POLICYCONTACT US

INTRODUCTION

ALICE helps hotels, properties, and other businesses (collectively, “Properties”) deliver better service by helping staff communicate with each other and with their guests. We want Property guests and staff to stay in control of their data. We do not sell guest data or use it to contact people for marketing purposes. We commit to strong privacy protection principles, as outlined in this privacy policy (“Policy”).

This Policy covers the policies and practices for how ALICE, an affiliate of FivePals, Inc. (hereinafter referred to as “ALICE,” “we,” or “us”) handles the Personal Data of visitors to our website www.aliceplatform.com (“Website”) and guests of Properties (“guests”) (collectively, “you,” or “your”) who use our web platform, mobile platform, or applications or products that link to this Policy (together, the “Services”). “Personal Data” is information that relates to an identified or identifiable individual.

This information is controlled by the relevant Property, and we are processors of that data. Please consult the privacy policy of your Property for the complete details of how your data is to be used to service your needs as part of your interaction with that Property.

Collection of Information

Information You Provide Directly to Us. When you use the services or engage in certain activities, such as registering, requesting services, or contacting us directly, we may ask you to provide some or all of the following types of information:

Contact information, such as full name, email address, telephone or mobile number, and address;

Demographic information, such as your gender, ZIP code, year of birth, and details about your personal preferences;

Payment information, such as credit card number, expiration date, and credit card security code, where needed to complete a transaction; and

Requests and other correspondence you send to us.

You can choose not to provide information to us directly, but some of this information is required to participate in some Services, such as registering or requesting services from Properties through the ALICE platform.

The best way to protect sensitive data is to not share it. Please do not enter private or sensitive information into the ALICE Services.

Information We Collect Automatically. We may collect certain information automatically through your use of our Services or other methods of web analysis, such as:

Location information as provided by your device or browser, such as your device's GPS signal or information about nearby WiFi access points;

Your Internet Protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the Internet;

Information about your device such as browser type, operating system, and Internet service provider; and

Information about your visit to our website such as pages that you visit before and after using the services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services.

Information We obtain from other sources. Properties send ALICE guest information regarding communications, requests, maintenance, and other service delivery. ALICE may also obtain information about you from other third-party services and organizations to enhance your experience.

Additionally, Properties may use additional technologies such as in-room entertainment to send service requests, which may contain Personal Data, to ALICE.

Cookies, Pixel Tags, Interest-Based Advertising, and Similar Technologies We, as well as Third Parties that provide content, advertising, or other functionality on our services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services.

We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, Services, applications, messaging, and tools, and to recognize you across devices.

Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Social Media Widgets. Our Website includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Data. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;

Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

USE OF INFORMATION

Personal Data.

The Personal Data we collect depends on the nature of your relationship with us:

We may collect Personal Data from Website visitors to:

Provide customized content and make recommendations that would improve your experience with the website

To serve you ads on our own services or elsewhere online that match your inferred interests, preferences, and characteristics

Send you content and communications including advertisements and offers, about our own and our trusted partners’ products and services

We may collect Personal Data from guests of Properties using our Services to:

For any activities that are necessary to support our contractual obligations to the Property

Provide customized content and make recommendations that would improve your experience with the app or Property. This includes, for example, preselecting the Property you are visiting when you open the ALICE app based on information you have given

Send you content and communications that you have requested or which are necessary for fulfilling our contractual obligations to you directly or via the Property

We may also process payments for products and services

We may collect Personal Data from staff members of a Property using our Services to:

Provide you with materials about offers, products, and services offered by us, including new content or services

Send you content and communications that you have requested or which are necessary for fulfilling our contractual obligations to you directly or via the Property

For any other activities that are necessary to support our contractual obligations to you directly or via the Property

We may collect Personal Data from all users of our Websites and Services to:

Analyze the use of the services and guest data to understand and improve the services and user experience and develop new services

Send you content and communications that you have requested or which are necessary for fulfilling our contractual obligations to you directly or via the Property

Conduct surveys, research, and evaluations

Prevent potentially prohibited or illegal activities

For other purposes we will disclose to you at the time we collect your information or pursuant to your consent

In addition, we use the Personal Data that we collect based on the following legal grounds and as necessary and appropriate for the following purposes:

To meet our legal obligations, for example:

For audit and reporting purposes, including internal and external investigations

To perform accounting and administrative tasks

To respond to requests for information by competent public bodies and judicial authorities

To enforce or manage legal claims.

Other Uses. ALICE may use Personal Data for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Data or with your consent.

Anonymous and Aggregated Information

We may use your Personal Data and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the services, or other analyses.

Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the services. Anonymized or aggregated information is not Personal Data, and we may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes.

DISCLOSURE OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

Properties

We share Personal Data with Properties you visit, as a byproduct of their using the ALICE platform to communicate with you. We do not control the privacy practices of these Properties, and their information practices are not covered by this Policy. We recommend that you visit the privacy policies of each Property that you visit.

Authorized Third-Party Vendors and Service Providers

We share Personal Data with third-party vendors and service providers that provide business services to us or on our behalf, such as IT services, payment processing services, to market products or services or deliver ads to you, analyze activity on the services, provide content, and help to maintain our user database and administer emails, surveys, or other communications. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.

We prohibit our service providers from using or sharing your Personal Data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Corporate Affiliates

We may share Personal Data with and among corporate affiliates and subsidiaries for their internal business purposes or to provide you with a product or service that you have requested.

Business Transfers

We may share Personal Data in connection with an actual or proposed change in control, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

Legal Purposes

We may disclose Personal Data to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to prevent fraud and to protect and defend the rights, interests, safety, and security of ALICE, our users, or the public.

With Your Consent

We may share Personal Data for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

If you access third-party services, such as Facebook, Google, or Twitter, through the services to login to the services or to share information about your experience on the services with others, these third-party services may be able to collect information about you, including information about your activity on our websites or through the services, and they may notify your connections on the third-party services about your use of the services, in accordance with their own privacy policies.

Anonymous and Aggregated Information

We may share anonymous or aggregated information within ALICE and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

RETENTION OF INFORMATION

ALICE retains the Personal Data we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

YOUR CHOICES AND RIGHTS

Cookies

You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable local storage and other technologies. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you.

Opting Out

You have the right to opt out of certain uses and disclosures of your Personal Data. Please note, if ALICE collected personal data about you from our Properties or on behalf of our Properties, please direct your query to the Property directly. ALICE will support our Properties as requested within a reasonable timeframe.

If you do not wish to receive marketing communications from us, you may opt out by clicking the “unsubscribe” link within the communication or by contacting us as at privacy@alice-app.com.

To opt out of other Personal Data processing, contact us at privacy@alice-app.com.

Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Data collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether ALICE is Processing Personal Data about you, request access to Personal Data, and ask that we correct, amend or delete your Personal Data where it is inaccurate. Where otherwise permitted by applicable law, you may contact us as described below to request access to, receive (port), seek rectification, or request erasure of Personal Data held about you by ALICE. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.Although ALICE makes good faith efforts to provide Individuals with access to their Personal Data, there may be circumstances in which ALICE is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If ALICE determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, ALICE will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Data.

California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those parties. ALICE does not currently share Personal Data with third parties for their own marketing purposes.

CHILDREN’S PRIVACY

ALICE’s Services are not directed to children under 16 and we do not knowingly collect Personal Data from children under the age of 16 without parental consent, unless permitted by law. If you are under the age of 18, you must have your parent’s permission to access the Services. If you learn that your child has provided us with Personal Data without your consent, you may contact us as described below. If we learn that a child under the age of 16 has provided us with Personal Data, we will delete it in accordance with applicable law.

THIRD-PARTY LINKS AND CONTENT

Some of the services may contain links to content maintained by third parties. We do not control the privacy practices of these third parties and they are not covered by this Policy. We recommend that you visit the privacy policies of any third-party content that you visit. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here.

DO-NOT-TRACK SIGNALS AND SIMILAR MECHANISMS

Some web browsers transmit "do-not-track" signals to websites. Because of differences in how web browsers incorporate and activate this feature, we currently do not take action in response to these signals.

PCI RESPONSIBILITY

ALICE is committed to preserving the confidentiality, integrity and availability of the physical and electronic information assets throughout the organization in order to comply with PCI Data Security Standard (PCI DSS).

INTERNATIONAL USERS

If you are accessing the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States.

The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to help ensure that your privacy is protected.

We utilize Standard Contractual Clauses to ensure that all Persona lData collected in the EU is adequately handled and protected. By using the services and providing us with information, you understand and agree that your information may be transferred to and stored on servers located outside your resident jurisdiction and in the United States by us and the third parties with whom we share it.

SECURITY

We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

ALICE has administrative, physical and technical security measures in place to protect against the loss, misuse, and alteration of the information under our control. We utilize commercially reasonable practices to protect your data.

CHANGES TO THIS POLICY

We may update this Policy from time to time. If we update this Policy, We will revise the “Effective Date” date above and post the new Policy. If there are any material changes to this Policy, we will notify as required by applicable law. We recommend that you review this Policy each time you visit the services to stay informed of our privacy practices. Your continued relationship with ALICE after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by ALICE.